Copy of Press Release issued today

Dear Sir

This is sent to you from the residents action group RAG in Cranage Cheshire.

Regarding the upgrade to a smart motorway from junction 16 to 19 by Highways England and the noise and pollution emanating from the M6.

RAG was formed in October 2017 to try to get something done to improve both the existing and proposed situation on completion of the upgrade to protect the resident’s health and wellbeing

Recently following a freedom of information request made by Cranage Parish Council and the Resident’s Action Group to Highways England, certain documents were released.

These documents contained some very startling information; they contained some 1500 private addresses that were used by Highways England in the computer modelling for noise that exists at present emanating from the M6 along with the predictions for when the smart motorway will be completed.

Every one of these both existing and predicted was listed to be way above the world health authority along with the EU limits for safe health of residents. That is 40 decibels at night and 55 decibels daytime.

  • The consequences from noise at these levels are set out in the WHO night time noise report.
  • They include mortality rates that lives are shortened.
  • Blood disorders and cardiovascular links including strokes and heart attacks.
  • Other studies show links to concentration being lowered prompting concerns over people using equipment that could lead to damaging themselves or others.
  • Also the effects on children leading to hyper active disorder  and associated behavioural complications
  • Mental health is also linked both in adults and children.
  • The loss of sleep or disturbed sleep is detrimental on health
  • The list in the WHO 184 page report is comprehensive and very disturbing and presents a very serious cause for concern.
  • It’s estimated that just from the highways document, which doesn’t include every property in the catchment area, some three thousand residents and that’s a conservative estimate will be affected.

Yet highways refuse to accept that there is a problem and insist that what they are doing is not significantly making things worse, totally ignoring that there was a problem to start with.

In 1994 when it was proposed to add extra lanes to the M6 the then Highways Agency stated that there was a problem over noise in Cranage and proposed to erect a noise fence on top of an earth bund to protect residents.

Now we have traffic levels predicted on completion to be double those in 1994 yet the highways England now say there is no problem.

What also came to light was that they failed to include all residents within 600 meters of the M6 when applying mitigation; indeed even some within 300 meters were not afforded the opportunity to apply for grants to improve their properties.

Also they failed to take any night time real life readings to back up their computer model,

All of which are required by the environmental assessment.

In their covering letter to the documents released they make the statement that they will not correspond with the parish council and the residents group further .

This coming from a public body is absolutely disgraceful and shows a total lack of respect and arrogance that is beyond belief.

The main issues are

Highways failed to do a full impact assessment required by statute, they requested this to be waived by the minister for transport without him being fully given the facts.

A full impact is required by law which would have resulted in a noise absorbing fence being installed what they did was only an environment assessment

That they failed to even carry out the environmental assessment correctly and excluded residents that should have been offered mitigation.

That they failed to take actual night time noise readings, again a requirement even in an environmental assessment let alone a full impact assessment.

That at a time when the government is failing to meet its legal requirements on noise and pollution the highways have the opportunity to significantly improve things in this area

Yet refuse to do so, but Its noted that the M40 is benefiting from noise absorbing fences so why are we being excluded.

The pollution is another aspect of concern coming from the M6, its very apparent that with no hard shoulder the M6 very quickly comes to an halt when an incident occurs leaving stationary traffic belching out pollution this happens several times a day on this section.

This section of the M6 junction 17 to 19 is one of the most if not the most disrupted section on a daily basis in the motorway network, figures obtained show this to be correct.

With no hard shoulder it becomes very dangerous for users, indeed the all-party commons committee stated that a halt should be made till further research into the safety of smart motorways  is carried out.

The results of every incident lead to all the adjacent roads becoming heavily congested with the increase in pollution to even more residents.

The cost burden to the health service resulting from the reduced general health by residents affected and these include children must be enormous.

The installation of noise absorbing fence technology would greatly reduce the impact on residents along with the reduction of particulate matter M10-M2.5 at source

Highways stance as always been that what they are doing is not significantly making things worse from the level of noise that already exists, and that this does not require them to deal with the problem, yet under the mandatory requirement set out by government it clearly states that a full impact assessment is required for such a scheme as this upgrade of lanes etc. The fact they requested a dispensation from the then minister for transport to not do a full impact assessment and to carry out only the lesser environment assessment shows a clear intent to circumnavigate the law.

For information the documents and reports we rely on are set out below

The general comments set out by RAG and circulated

The recent details from highways England  revealed under a freedom of information request made by RAG and Cranage Parish Council are a cause for concern.

This document produced by RAG sets out to highlight several aspects of the FOI documents received.

In the first part of their covering letter they refer to the distance  from the motorway that should be part of the consultation zone and apologise for the fact that 300 metres was applied not the 600 meters that is the statutory requirement even at 300 metres several residents were excluded from consideration for mitigation measures.

FOI request showed that highways England had used a computer generated model for noise levels on 1500 properties along the M6 from junction 16 to 19 .

The model showed that not one property was below the level for night time noise of 40 decibels recommended by the WHO and by the directive issued by the EU to all member states.

It also showed and they stated they had not carried out any real time observations for night time noise.

It’s been established in the past that highways are of the opinion that they do not need to do a full impact assessment, only an environment one,

We would draw attention to the roads and bridges design documents set out below.

Extract taken from roads and bridges design manual volume 11 section 2

  • “This document is a Standard and mandatory
    sections apply.
    mandatory sections
    2 Mandatory sections of this document are
    contained in boxes. The Service Provider must
    comply with these sections or obtain agreement
    to a Departure from Standard (or equivalent) from
    the Overseeing Organisation. The remainder of the
    document contains advice and explanation, which
    is commended to users for consideration

 

 

Construction of motorways and express roads. Construction of a new road of four or more lanes, or realignment and/ or widening of an existing road of two lanes or less so as to provide four or more lanes, where such new road, or realigned and/or widened section of road would be 10 km or more in a continuous length

 

I RAGs view the M6 scheme falls into this category that requires a full environmental impact assessment to be carried out, this highways have failed to do by only doing an environmental assessment.

We also note that highways use the physics lab method of calculating noise levels by computer generated modelling , the physics lab also note that this does not factor in any elements for wind direction and weather conditions.

Also it should be born in mind that the section that runs through cranage is mostly flat with no embankments. Leading to exposure from wind carried noise.

Further we would draw attention to the WHO night time noise report

“Average night noise Health effects observed in the population
level over a year
L
night,outside
Up to 30 dB Although individual sensitivities and circumstances may differ, it appears that up to this level no substantial biological effects are observed.
L
night,outside of 30 dB is equivalent to the no observed effect level (NOEL) for night noise.
30 to 40 dB A number of effects on sleep are observed from this range: body movements, awakening, self-reported sleep disturbance, arousals. The intensity of the
effect depends on the nature of the source and the number of events. Vulnerable groups (for example children, the chronically ill and the elderly) are
more susceptible. However, even in the worst cases the effects seem modest. L night,outside of 40 dB is equivalent to the lowest observed adverse effect
level (LOAEL) for night noise.

40 to 55 dB Adverse health effects are observed among the exposed population. Many people have to adapt their lives to cope with the noise at night. Vulnerable
groups are more severely affected.
Above 55 dB The situation is considered increasingly dangerous for public health. Adverse health effects occur frequently, a sizeable proportion of the
population is highly annoyed and sleep-disturbed. There is evidence that the risk of cardiovascular disease increases.

For the primary prevention of sub clinical adverse health effects related to night noise in the population, it is recommended that the population should not be
exposed to night noise levels greater than 40 dB of Lnight,outside during the part of the night when most people are in bed. The LOAEL of night noise, 40 dBL night,outside, can be considered a health-based limit value of the night noise guidelines (NNG) necessary to protect the public, including most of the vulnerable groups such as children, the chronically ill and the elderly, from the adverse health effects of night noise.”

It should be noted that this refers to night time levels taken outside not inside a misconception applied by some.

Further we would also draw attention to the EU directive and its amended  directive 2011/92/EU 16th April 2014.

Which contains numerous paragraphs underlining the requirement to carry out a full impact assessment for such a scheme that the M6 falls under.

In Defra’s noise action plan dated July 2013 it states

  • “The Government‟s policy on noise is set out in the Noise Policy Statement for
    England (NPSE). The NPSE‟s vision is to:
    “Promote good health and a good quality of life through the effective
    management of noise within the context of Government policy on sustainable

    Its aims are to:
    · avoid significant adverse impacts on health and quality of life;
    · mitigate and minimise adverse impacts on health and quality of life; and
    · where possible, contribute to the improvement of health and quality of life.

1.4 The NPSE provides the policy framework to assist the implementation of the END eviromental noise directive 2002/49/ec
and the Regulations.”

Further there are safety concerns raised by the all-party House of Commons Transport Committee All Lane Running 2016-2017 .

In their report they state and highlight the following.

Cost savings are at the heart of the Department’s justifcation for the permanent conversion of the hard shoulder into a running lane. Andrew Jones denied that this was a design “on the cheap”, telling us that this was a key ingredient in a £15 billion national strategic road network budget over this spending period.100 Te Government’s preference for All Lane Running is based on the fact that extra capacity can be obtained at a 60%
lower cost than traditional road widening. Te fact that All Lane Running is the least costly of the scheme designs cannot be challenged. That this involves the loss of the hard shoulder, resulting in a risk to safety, is another matter and is not justifiable.
77. We do not support the deployment of all lane running. Given that Highways England’s own risk assessments show that other forms of smart motorway are safer
than All Lane Running, and still improve capacity, we recommend the design of the M42 Active Trafc Management pilot, or, less preferably, Dynamic Hard Shoulder
Running as safer alternatives. Te cost saving of All Lane Running cannot justify the increase in risk of certain hazards.

78. Te Department would do well to decouple its thinking, and not assume that the loss of the hard shoulder is essential for the installation of a controlled environment.
Te “smart” in smart motorways does not come from the loss of the hard shoulder, but for motorists this is undeniably the most disturbing aspect of the changes. It could be
seen as disingenuous to present this change as part and parcel of “smart” motorways. Te Department cannot use a reduction in risk in some hazards to justify an increase
in risk in others.

 79. It is not justifiable for the Department to go ahead with a major motorway programme with only one year’s worth of safety information from the specifc design
that they have chosen. The All Lane Running design has been chosen on the basis of costsavings, and it is not acceptable for the Department to proceed with a less-safe design, 
putting people’s lives at risk, in order to cut costs. 

80. We recommend an immediate halt to the rollout of All Lane Running, and that the proposed schemes be replaced by schemes based on the M42 Active Traffic Management 
design. That is, a design incorporating the temporary use of the hard shoulder as required, gantries spaced at a distance of 500–800 metres, and emergency refuge areas
spaced at the same distance.

The document below is from

House of commons library in it you will see a reference to 300 metres, it must be pointed out that several residents were excluded from being considered for any mitigation or compensation and a number have spent a great deal of money trying to protect their houses from the noise levels ,certainly of the 1500 listed the majority will not be aware that they might have been considered

Again you will see that an environmental impact assessment should have been carried out.

Roads: traffic noise
Standard Note: SN/BT/347
Last updated: 10 November 2010
Author: Louise Butcher
Section Business and Transport

Noise. For example, about 57 million people are annoyed by road traffic noise, 42% of them seriously.

A preliminary analysis shows that each year over 245,000 people in the EU25 are affected by cardiovascular diseases that can be traced to traffic noise. About 20% of
these people (almost 50,000) suffer a lethal heart attack, thereby dying prematurely. The annual health loss due to traffic noise increased between 1980 and 2000 and is
expected to increase up to 2020. In contrast, traffic safety has improved, following implementation of a variety of policy measures.4

The EU Environmental Noise Directive (2002/49/EC) requires noise levels to be assessed from road traffic, railways, major airports and industry. The Directive was implemented in the
UK by the Environmental Noise (England) Regulations 2006 (SI 2006/2238). Regulation 7 requires the Secretary of State to make strategic noise maps for agglomerations, major
roads, major railways and major airports. The first round of strategic noise maps was produced in 2007 and the second will be published in 2012. In the second round a larger
number of the same type of noise sources will have to be mapped than in the first round. Subsequently, strategic noise maps will have to be made every five years

When proposing the construction of a new road, or an additional carriageway to an existing road, a noise impact assessment must be carried out. For large scale projects,
an Environmental Impact Assessment is required by law, which would include a noise impact assessment. In addition, the Highways Agency requires a noise impact
assessment to be undertaken if there is an expected increase of 1 dB LA10,18h as a result of any works it carries out on its network, including maintenance. The process
which tends to be followed is set out in the Design Manual for Roads and Bridges.

Mitigation such as optimising the route alignment and the use of noise barriers, either through landscaping or purpose built walls or fences, is included in the design to
minimise any adverse noise impact. This process also has regard to the protection of tranquil areas in general through consideration of the impact on landscape.

Guidance 24 that provides guidance on land use with respect to noise from road traffic.16 One of the most popular noise mitigation measures is noise barriers. Highway authorities
have the power to implement noise barriers where traffic will cause excessive noise. The locations in which barriers are erected are determined by their eligibility to be put forward for
consideration and prioritisation by the Highways Agency, following testing of the noise at the location. Once a site has been selected, however, it is down to the highway authority’s
interpretation of the (non-statutory) Design Manual for Roads and Bridges as to how and where exactly the barrier will be located.17 The manual sets out the statutory obligations of
the highway authorities in cases where noise pollution is an issue: Under the respective legislation, occupiers of property within 300m of a new road are
entitled to be offered appropriate insulation if the noise from traffic on it reaches a specified level at the property. The entitlement to insulation is governed by the Noise
Insulation Regulations which refer to the method of noise prediction to be used […] The occupier of a property may also claim monetary compensation for any loss in
value of the property caused by the presence of the road. Compensation may be payable even where the noise at a property does not reach the qualifying level and
whether or not it is situated within 300m of the road. Careful consideration of road alignment options and mitigation measures can avoid noise and visual intrusion on
properties, with consequential savings in compensation costs. Highway authorities are empowered to carry out “works for mitigating any adverse
effect which the construction, existence or use of a highway has or will have on its surroundings”. They are also given the power to acquire land additional to that needed
for construction of the road itself to permit landscaping or the creation of earth mounds. The interpretation of “works” in this context is fairly broad and includes amenity
treatment such as grassing and planting of trees and shrubs on landscape areas. In this context both noise and visual intrusion are adverse effects which can properly be
mitigated by the use of earth mounds, barriers and planting.

The letter produced below was sent to a resident in 2015 in it it states that Defra acknowledge oak tree lane as an important area

Conclusions

That highways should have carried out a full impact environmental assessment which would have included a night time noise assessment.

That highways failed to implement the correct distance for consultation and possible mitigation.

That 1500 residential properties are being subjected to a noise level that is above the EU and WHO directives which means conservatively over 3000 residents are directly impacted.

That highways failed to do a night time noise assessment in real terms

That in june 2015 its stated a noise hot spot or important area was designated by Defra for oak tree lane in Cranage.

Documents listed and referred to numbers 1 to 8a can be downloaded via the Cranage Parish Chronicle via this link

https://cranageparishchronicle.co.uk/m6-freedom-of-information-noise-pollution/

Regards

Peter wild chairman of RAG

Residents Action Group  (RAG ) committee members
Chairman Peter Wild ,   Treasurer   Inam Choudhry ,   Secretary Joan Wild,   Andrew Kolker  Cheshire East  Councillor,
Mike Hodge  Cranage Parish Councillor,      Stuart Jackson .


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